Status: Invoice-element communication is in force. The accounting SAF-T (PT) pre-submission timetable has been postponed: it applies to 2027 and later periods, to be submitted in 2028 or later.
Verified on: 10 July 2026
“Portugal SAF-T” is often used for two related but legally distinct processes. The first is the recurring communication of invoice and other fiscal-document elements to the Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira, or AT). The second is the accounting SAF-T (PT) file intended to support pre-filling of the annual Simplified Business Information return, known as IES. Treating these as one monthly accounting-file obligation creates an inaccurate project scope.
1. Monthly communication of invoice elements
People and entities subject to Portuguese invoicing rules under article 35-A of the VAT Code, and carrying out transactions subject to VAT in Portugal, must communicate specified elements of issued invoices. The obligation also covers elements of documents used to verify the delivery of goods or provision of services, and receipts.
The general deadline is the fifth day of the month following the document’s issue. The consolidated decree provides three channels:
- electronic transmission of data in real time;
- electronic transmission using a normalised file structured from SAF-T (PT); or
- direct entry in the Portal das Finanças.
Taxpayers required to produce SAF-T (PT) must use the real-time or SAF-T-based route, rather than direct portal entry. The communicated data includes identifiers for supplier and customer where applicable, document number and date, document type, taxable amount, tax rates, exemption reason where applicable, VAT or stamp-duty amount, software certificate number, references to original or corrected documents, country or tax region and the unique document code.
This is a communication of prescribed document elements. It should not be described as a routine monthly upload of the full general ledger or full accounting SAF-T file.
2. Accounting SAF-T (PT) and IES
The accounting SAF-T (PT) process is governed separately. Portugal’s 2026 State Budget states that submission of the accounting file under Portaria 31/2019 applies to periods in 2027 and later, with delivery in 2028 or later. As at the verification date, businesses should prepare the accounting data and mapping needed for that future annual process, but should not present accounting SAF-T pre-submission as an already-live monthly obligation.
The operational timeline should therefore distinguish:
- now: recurring invoice/document-element communication by the fifth day of the next month;
- 2027 periods: first periods to which the postponed accounting SAF-T rules apply;
- 2028: first submissions for those 2027 periods, subject to the then-current AT specifications and filing instructions.
Format and channel controls
The SAF-T (PT) route uses the official normalised structure created by Portaria 321-A/2007, as amended. Implementations should generate against the schema and validation rules currently published by AT, not a copied or hard-coded historical layout. Real-time communication and file upload are separate technical patterns; the selected route should be documented per Portuguese registration and invoicing system.
Submission evidence, rejected-file messages and corrected transmissions should be retained. A technically accepted message does not remove the need to reconcile the communicated data to the underlying invoice and VAT records.
What this means for an SAP landscape
A credible SAP design separates invoice communication from the future accounting extract. For monthly document reporting, teams should establish which SAP or connected billing systems issue Portuguese documents, then control numbering, dates, document types, NIF values, tax codes, exemption reasons, correction references and identifiers required by AT. Interfaces must account for cancellations and corrections without losing the link to the original document.
Accounting SAF-T readiness adds a broader workstream: chart-of-accounts mapping, general-ledger completeness, master data, opening and closing balances, year-end adjustments and reconciliation to the IES population. That work should be planned against the 2027-period start while keeping monthly invoice reporting stable.
- Inventory every Portuguese invoicing source and legal registration.
- Confirm whether each source uses real-time transmission or a SAF-T-based file.
- Reconcile AT responses to SAP document status and finance totals.
- Keep the future accounting-file mapping as a separate, version-controlled deliverable.
- Re-check AT schemas and 2028 filing instructions before go-live.
Primary sources
- Diário da República — Decree-Law 198/2012, consolidated, article 3
- Diário da República — Law 73-A/2025 (2026 State Budget), article 95
- Portal das Finanças — e-Fatura communication and web-service specifications
- Portal das Finanças — IES with SAF-T (PT), 2027-and-later XML schema
Regulatory information only; not tax or legal advice. Confirm scope, current schemas and filing procedures with AT and qualified Portuguese advisers for each entity and invoicing flow.
To separate monthly invoice reporting from 2027-period accounting readiness in your SAP roadmap, request a scoped readiness review.
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